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September 9, 2021

Monday, 20 September 2021 | US international tax reform: Update on recent developments (1 pm ET)

Significant international tax changes have been proposed this year, including the Biden Administration’s Made in America Plan (as outlined in the Green Book) and a discussion draft of Senator Ron Wyden’s international tax framework, among others. Many of these changes would significantly affect the global taxation of multinational corporate groups.

Join our panelists as they discuss the various proposals, including the following:

  • Potential changes to US taxation of offshore income under the rules for global intangible low-taxed income (GILTI), subpart F, and foreign branch income, along with the related foreign tax credit implications
  • Potential changes to the rules for foreign-derived intangible income (FDII), as well as the outlook for R&D capitalization under Section 174
  • Potential modifications to the base erosion anti-abuse tax (BEAT), including the potential for incorporating elements of the proposal for Stopping Harmful Inversions and Ending Low-Tax Developments (SHIELD)
  • Developments at the Organisation for Economic Co-operation and Development, particularly the Pillar One and Pillar Two proposals, and how these proposals may influence US tax legislation
  • What companies should be doing now

Date:                   Monday, 20 September 2021

Time:                  1:00–2:30 p.m. EDT New York; 10:00–11:30 a.m. PDT Los Angeles

Registration:     Register here.


  • Ray Beeman, Leader, Washington Council Ernst & Young, Ernst & Young LLP
  • Jeff Michalak, EY Global International Tax and Transaction Services Leader
  • JD Hamilton, International Tax and Transaction Services, Ernst & Young LLP
  • Anna Voortman, International Tax and Transaction Services, Ernst & Young LLP


  • Colleen O’Neill, Director of International Tax and Transaction Services, National Tax Department, Ernst & Young LLP

CPE credit offered: up to 1.8 depending on actual duration. Recommended field of study: Taxes. Learning objectives: Describe recent US international tax proposals; assess how potential tax legislative changes might affect multinational companies; explain how global tax policy developments and trends might affect US tax legislation. This intermediate level, group internet-based course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.

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